Legal
Privacy Policy
This Privacy Policy explains how CashFlow Limited ("CashFlow", "we", "us") collects, uses, shares, and protects personal data across our websites, applications, and disbursement platform. Last updated: 15 August 2026.
This Privacy Policy explains how CashFlow Limited ("CashFlow", "we", "us") collects, uses, shares, and protects personal data across our websites, applications, and disbursement platform. It applies to Organizations that use CashFlow and to the beneficiaries whose data is processed through it, in line with applicable data-protection law in the Republic of Sierra Leone. By using CashFlow, you agree to the practices described here.
1. Overview
This policy covers all CashFlow properties and services, and describes our commitment to handling personal data lawfully, fairly, and transparently.
2. Eligibility
CashFlow is intended for use by registered organizations and their authorized representatives, who must be at least 18 years of age.
3. Consent
By registering, funding a payment pool, or submitting beneficiary data, you consent to the collection and use of personal data as set out in this policy.
Organizations confirm they have a lawful basis to share beneficiary personal data with CashFlow for verification and disbursement.
4. Lawful Basis for Processing
We process personal data on one or more of the following bases: your consent, performance of a contract, compliance with a legal obligation, our legitimate interests, and the public interest in delivering humanitarian and government disbursements.
5. Information We Collect
Organization data: legal entity details, authorized contacts, and program ownership.
Beneficiary data: identity details, eligibility information, KYC documentation, and payout destinations (Mobile Money, bank, or wallet).
Technical data: IP address, device and browser information, and platform activity logs.
6. How We Collect Information
We collect information directly from you and your beneficiaries, automatically through cookies and server logs, and, where relevant, from verification and payment partners.
7. How We Use Your Data
We use personal data to deliver the platform, validate beneficiaries, execute disbursements in SLE, prevent fraud, provide support, generate reports, and meet regulatory obligations.
8. Fraud Prevention & AML
We run fraud, sanctions, and anti-money-laundering checks. Where unlawful activity is suspected, we may restrict funds and share relevant details with competent authorities.
9. Analytics & Aggregation
We may use pseudonymized, aggregated data to improve the platform, measure program performance, and develop new features. Aggregated data cannot identify an individual.
10. Your Rights
Subject to applicable law, you have the right to access, correct, delete, or object to the processing of your personal data, and to request portability. To exercise these rights, contact our Data Protection Officer.
11. Data Retention
We retain personal data only as long as necessary for the purposes described here or as required by financial and regulatory obligations, after which it is securely deleted or anonymized.
12. Security of Your Data
We protect personal data with technical and organizational safeguards, including strong encryption, role-based access, audit logging, and defined breach-response procedures.
15. Updates to This Policy
We may revise this policy from time to time. Material changes will be notified through the platform or by email, and continued use constitutes acceptance.
16. Contact
Questions about this policy or your data can be directed to the CashFlow Data Protection Officer at privacy@cash-flow.space.
This document is a plain-language summary and does not constitute legal advice.